Insurance strategy

VicSuper has developed key design considerations to guide the review and development of the VicSuper insurance offer. These principles were developed taking into account the VicSuper business plan objectives.

Design considerations

Supports Fund Growth

MySuper offer must be competitive relative to the fund’s key competitors in the employer and direct to member markets.

Provide levels of insurance cover that would meet the reasonable needs of most members without inappropriately eroding members’ account balances.

Sustainability

Promoting a benefit design and a set of policies, procedures, and practices that give rise to a stable claims experience across the medium to long term.

Rehabilitation

Reduce claims waiting periods and refocus on early intervention, vocational rehabilitation and, where possible, helping members return to work.

Eligibility

Insurance arrangements with flexible features whilst also ensuring that appropriate eligibility conditions for automatic cover.

Affordability

Provide a level of default cover that is set at an affordable level. Default cover is considered affordable where the premium is less than 15% of the average annual superannuation guarantee contribution, under each age segment.

Flexibility

Allow for more cover where required - members can apply for additional cover subject to underwriting.

The insurance offer is reviewed on a regular basis. The review includes looking at the type of cover provided, the level of cover and the cost of that cover.

All benefit change considerations takes into account the requirements of SPS250 and section 52(7) of the SIS Act and is approved by the Trustee.

VicSuper has agreed to adopt the Insurance in Super Voluntary Code of Practice and is currently in transition phase.

All change considerations must consider this Code of Practice with compliance achieved by 30 June 2021.

Claims philosophy

VicSuper’s claims philosophy is to:

be there for our members, and their beneficiaries, in their time of greatest need make the claims process simple and stress free, while providing multiple channels to initiate a claim

verify that all genuine claims are paid as quickly as possible

treat all members and their beneficiaries with respect and understanding

benchmark claim payout ratios against the group insurance industry.

To achieve this, VicSuper works with its members and beneficiaries through the claims process, liaises with the Insurer to bring the best possible result and verify that staff are representing the interests of members at all times.

VicSuper reviews the Insurer’s claims philosophy (part of claims guidance manual) and confirms that it aligns with the VicSuper claims philosophy.

Code of conduct for all employees

Everyone working for VicSuper is required to understand and comply with our code of conduct.

The code is integral for our commitment to sustainability and our values - making sense, always help, trust and integrity, respect and encouragement, learning and quality.

VicSuper’s Conflicts Management Framework and Conflicts Management Policy are designed to enable us to clearly identify, avoid or manage material conflicts of interest or duty that may arise as trustee of the Victorian Superannuation Fund (Fund) and as an Australian Financial Services Licensee (AFS Licensee).

VicSuper has determined its current ‘responsible persons’ to be directors, General Counsel and Company Secretary, executive managers, external auditors and any actuaries appointed for the purpose of the SIS Act.

VicSuper is committed to managing our corporate governance and active ownership obligations. We recognise we have rights and responsibilities as a shareholder and co-owner of the companies we invest in.

Our policy demonstrates how we meet our active ownership obligations as a signatory to the Principles for Responsible Investment (PRI) Principle 2.

Marketing and compliance

We comply with the relevant Federal Government legislation in all our product features and information.

We also discuss the economic, social and environmental impacts of our products and services in our Annual Report and our Product Disclosure Statements.

We publish the terms and conditions of any competitions and promotions on our website and comply with relevant state and federal legislation.

Licensing

VicSuper is licensed under the Corporations Act 2001 (Cwlth).

Under the terms and conditions of our Australian Financial Services Licence (AFSL No. 237333), VicSuper may deal in, and advise on, superannuation products.

At present, VicSuper representatives are limited to providing financial product advice on VicSuper products; ESSSuper – Revised, New, SERB and Transport Schemes; providing advice on whether a member should consolidate or roll over their superannuation holdings into VicSuper (excluding personal advice on self-managed superannuation funds); and general superannuation matters.

Before a VicSuper employee can be authorised to provide general or personal advice, the nominated employee must be approved by two delegates of the Trustee and meet minimum qualifications, training and experience criteria.

VicSuper is not a member of any financial group nor do we have any ownership links or affiliations that would have any effect on the advice provided by our representatives under VicSuper’s AFSL.

All superannuation trustees must be issued with a RSE (Registrable Superannuation Entity) Licence by APRA to act as a trustee, and the super fund must be registered with APRA to accept contributions. VicSuper Pty Ltd’s APRA RSE Licence number is L0000468. To obtain its RSE Licence, VicSuper had to demonstrate it has policies and procedures to deal with responsibilities such as risk management and resource adequacy. VicSuper Fund’s APRA registration number is R1000580.

In February 2013, VicSuper was also issued with its MySuper authorisation from APRA (unique identifier: 85977964496198), which means we will continue to be an eligible default fund for employers after 1 January 2014.

Internal controls

VicSuper has a comprehensive system of internal controls, including:

a compliance framework

a risk management framework and risk management strategy

regular compliance and risk management reports to the Trustee

a AFSL implementation framework

regular legislative and technical updates to all employees and directors

fraud control processes and fraud awareness training for all employees

All new employees receive training in fraud prevention and anti-corruption as part of their induction.

Committees

VicSuper's Board has established several committees to assist in assessing, reviewing and implementing its responsibilities. These include:

Audit, Compliance & Risk Management Committee which is a committee of the Trustee. It assists the directors with the financial, compliance and risk management of VicSuper Pty Ltd and VicSuper Fund.

Investment Committee which is a committee of the Trustee tasked with making recommendations to the Trustee on investment policy, strategy and investment activities, as well as the review and monitoring of VicSuper’s investments.

Remuneration Committee which provides advice to the Trustee on remuneration matters.

Mergers Steering Committee was established to provide timely responses to interested parties, to provide a method of having non-binding dialogue in the preliminary stages of a merger and be involved in face to face discussions and negotiations with potential merger partners.

VicSuper does not have a separate committee for sustainable development issues but aims to integrate this into all decisions made by the Board.

Risk management

Our Compliance and Risk Management Frameworks and Code of Conduct work together to help ensure we make informed, balanced and ethical business decisions. The Risk Management Framework (RMF) outlines our commitment to risk management for the benefit of the Fund and our members. Key elements of the RMF are illustrated in the diagram below.

Our risk management approach

The Risk Management Framework (RMF) is comprised of the Risk Management Framework Policy, the Risk Management Strategy and the Risk Appetite Statement. It is updated at least annually to help ensure compliance with regulations and APRA Prudential Standards. In accordance with SPS 220 Risk Management it is also subject to a comprehensive review every three years by an independent party.

The objectives of the RMF are to:

maintain a coordinated and structured approach to risk management

establish a systematic process for identifying and actively managing risks

outline roles and responsibilities for managing risk at VicSuper

enhance awareness of risk across the business and embed management of risk into day-to-day activities.

The RMF Policy outlines our risk profile and our risk management structure. It is supported by VicSuper’s Risk Management Strategy (RMS) which provides further guidance around how risk management is implemented across the Fund. The RMS is updated on an annual basis to help ensure that it aligns with our purpose, criteria for success and key strategies. It also includes the material risks and mitigation strategies in place. Performance against the RMF is reported to the Audit Compliance and Risk Management Committee and the Board through periodic risk reporting.

The Board reviews and approves the RMS and sets the overall risk appetite for VicSuper which is documented in the Risk Appetite Statement. The Executive Team monitors VicSuper’s risk profiles and reviews the operating effectiveness of key controls within the business on a regular basis. The risk management structure helps ensure risk management is performed at all levels of the Fund in accordance with the RMF.

Maintaining compliance

The Compliance Framework sets out systems and procedures in place to assist VicSuper in meeting its legislative and regulatory compliance requirements. Responsibility for ensuring compliance with these sits at various levels within our business.

As a holder of an Australian Financial Services Licence (AFSL) and a Registerable Superannuation Entity (RSE) Licence, VicSuper is obliged to meet a number of licence obligations. We are also obligated to report significant licence breaches or potential breaches to the relevant regulator (ASIC and APRA).

Our AFSL & RSE Breach and Incident Reporting Policy and Guidelines outline when and how a breach or incident is to be reported. Compliance concerns or breaches are reported to the Compliance and Risk Management Team. They adopt a careful and diligent approach when reviewing and assessing incidents and breaches. Reports are provided to the Audit, Compliance and Risk Management Committee, the Board and the regulator if required. All breaches and potential breaches are recorded on our Breach Register together with supporting documentation.

Financial controls

VicSuper uses independent auditor Deloitte Touche Tohmatsu to conduct an external audit of VicSuper's and VicSuper Fund's financial statements. The audit for a financial year is completed in September of the following financial year.

Custodians

A custodian is a specialist organisation that holds title to an investor's assets, undertakes registration of securities, holds investments in safe custody and maintains accounting and taxation records on the investor's behalf. VicSuper Fund's custodians are currently National Australia Bank (AFSL 230686) and Westpac Banking Corporation (AFSL 233714), which maintains VicSuper Fund’s bank account.

Our stakeholders

Our business is built on relationships and these relationships extend far and wide. Each and every one of them is important – whether it’s with the people who rely on us to look after and grow their retirement savings, and the employers who place their trust in us above all other super funds, or the communities in which operate. In fact all of these groups are essentially stakeholders in VicSuper. We work with these stakeholders in range of different ways.

Our members

Our members are our largest stakeholder group – they’re why we do what we do. We interact with members in all sorts of ways: through face-to-face and online seminars, over the phone and in writing, via social media, via our website, and through VicSuper MembersOnline (desktop and mobile). We also survey our members through our Voice of the Customer survey program, gathering their feedback at different stages of their superannuation journey with us. And we use this feedback to constantly refine and improve what we’re doing.

Our employers

We support thousands of employers Australia-wide, big and small. On any given day our Business Development, Employer Services and Financial Advice teams are working with employers, providing support, information, answering questions, and outlining super obligations. We make it as simple as possible for them to manage the administrative tasks associated with providing super to their employees, using tools such as digital access to EmployersOnline and our Clearing House solution. And we conduct workplace seminars, webinars and workshops to help build their understanding of super and their obligations.

VicSuper employees

We want our employees to love what they do and to feel supported in what they do. We formally engage with each employee on their performance and development objectives twice a year. We also collect their feedback through the annual VicSuper Voice survey. Our People Committee shares insights on this feedback with our management team so that we can develop initiatives that help make VicSuper a great place to work. Our employees receive regular updates on VicSuper’s performance through CEO-led breakfast seminars, team meetings, our intranet and our internal social media platform.

Investment managers, advisers and consultants

Our investment managers, advisers and asset consultants provide our management team and the Trustee with strategic investment advice on how to respond to changes in the economy and our external environment. Whenever we appoint a new investment manager, we undertake a thorough due diligence process and, once appointed, we hold regular meetings and teleconferences. We also receive feedback and reports from third-party specialists who engage with the companies we invest in on environment, social and governance issues.

The service providers we engage

We try to work with suppliers whose values are aligned to ours. We look for opportunities to maximise innovation, efficiency and continuous improvement for both parties. We undertake due diligence prior to the appointment of new suppliers or business partners, in order to develop more proactive and collaborative working relationships.

Government, regulators and voluntary organisations

We regularly meet and engage with government representatives on issues including industry reform, policy development, economic development and the natural environment. We participate in public policy discussions through industry forums, networks and working groups. We engage in industry change initiatives through our voluntary signatory organisations, including the Principles for Responsible Investment, the United Nations Environment Programme Finance Initiative and the Natural Capital Declaration.

Industry associations

We participate in a number of industry associations, either as direct members or through collaborations. We also participate in round tables and collaborate in research projects with industry peers, experts and local business leaders.

The Victorian community

Every year we run a broad range of advice and education initiatives to help build financial skills and knowledge in the Victorian community – largely through our Community Connect program. These freely available initiatives are delivered to targeted groups within our community, including women, Millennials and Gen Y, redundant workers and pre-retirees. We also participate in research projects which seek to contribute to economic innovation and jobs growth in the community. Our employees also make individual contributions to the community, participating in company volunteering and fundraising activities.